State v. Lewis’s Empirical Analysis
2007
Citation profile
59 state decisions
How this case has been cited
Cited by 61 later decisions — most recently December 2025 · most notably Tennie Martin, et.al. v. Southern Railway Company, et.al. (2008), State v. Appleby (2009)
59 state decisions — followed in 14 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Crawford v. Washington · Ohio v. Roberts · Davis v. Washington · Pennsylvania v. Ritchie · Maryland v. Craig
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Statements are nontestimonial when made in the course of police interrogation under circumstances objectively indicating that the primary purpose of the interrogation is to enable police assistance to meet an ongoing emergency. They are testimonial when the circumstances objectively indicate that there is no such ongoing emergency, and that the primary purpose of the interrogation is to establish or prove past events potentially relevant to later criminal prosecution.”
2 later decisions quote this exact passage · from the majority“Since Crawford , we found no jurisdiction diat has excluded a testimonial dying declaration. Several states have specifically allowed the declaration as an exception to the rule in Crawford. See, e.g., Wallace v. State, 836 N.E.2d 985, 992-96 (Ind.Ct.App.2005); State v. Young, 710 N.W.2d 272, 283-84 (Minn.2006).”); People v. Monterroso, 34 Cal.4th 743 , 22 Cal. Rptr.3d 1 , 101 P.3d 956, 971-72 (2004) (”
2 later decisions quote this exact passage · from the majority“The assailant had left the store. The victim had talked to [the next door employees] who were first to arrive at the scene. The 911 call had already been made. In Davis, the Court pointed out that “the fact that [statements were] given at an alleged crime scene and were ‘initial inquiries’ is immaterial.” [ 547 U.S. at 832 , 126 S.Ct. 2266 ]. While the victim’s statements here took place at the crime scene, they were responses to inquiries by the investigating officers. Even though the victim was in a state of distress from his wounds, his comments did not describe an “ongoing emergency,” as defined in Crawford , and were instead descriptions of recent, but past, criminal activity as in Hammon [the companion case to Davis ].”
1 later decision quote this exact passage · from the majoritye.g. State v. Parker
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.